Our Federal Tax Group highlights a rule that exempts certain small business stock sales from taxes. What kinds of small companies are ideal candidates for qualified small business stock (QSBS) gain exclusions?...more
Our Federal Tax Group examines the signature difference brought about by tax reform’s opportunity zone regime.
Comparison to empowerment zones and enterprise communities -
How the new regime is being used.
How seriously...more
Notice 2015-59, 2015-40 IRB 459, issued last September, suggests that the IRS has concerns about several aspects of Section 355 tax-deferred spinoffs. One of these is the relevance of the 1986 repeal of the General Utilities...more
In January 2016, the Sixth Circuit reversed the Tax Court and ruled for the taxpayer in Wright v. Commissioner, 809 F. 3d 877 (6th Cir. 2016). If the IRS agrees, the ruling means that foreign currency contracts that are...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
9/2/2015
/ Business Assets ,
Capital Gains ,
Commercial Real Estate Market ,
Cross-Border Transactions ,
Foreign Affiliates ,
Goodwill ,
Intangible Property ,
Real Estate Investments ,
Related Parties ,
Section 1031 Exchange ,
Tax Planning